Entry into Force of the Protocol Amending the Convention between the Government of Japan and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income

November 5, 2007

The Governments of Japan and France completed on October 26 (Fri) the mutual notifications which are required for the entry into force of “The Protocol Amending the Convention between the Government of Japan and the Government of the French Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income” (hereinafter referred to as the “Protocol” signed on January 11, 2007).
The Protocol will enter into force on December 1 (Sat) and will be applied in Japan as follows:

(1) With regard to the withheld taxes, for the amount taxable on or after January 1, 2008.

(2) With regard to non-withheld taxes, for the income of any taxable year on or after January 1, 2008.

(3) With regard to other taxes, for taxes in any taxable year on or after January 1, 2008.

Having getting closer economic relations between Japan and France, the Protocol partially amends the current convention effected since 1996, with a view of promoting mutual investment between the two countries and taking measures to prevent fiscal evasion. The Protocol regulates a tax reduction or an exemption from taxation on the withholding taxes imposed on dividends, interest and royalties paid to both countries. The Protocol also introduces, in connection with the Japan-France agreement on social security, an exemption from income tax that either country gives the allowance as a credit against income of the social insurance premiums even paid in the other country.

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